Dear ALAC Leadership and the greater community, I am submitting the following memorandum for your consideration: http://knujon.com/DONT_analysisoficannwdprs.pdf What you will find in this document is an analysis of the ICANN complaint system (WDPRS). The analysis uses one criminally-used domain with false WHOIS as an example to better understand the issues with ICANN policy and procedure. In short, the ICANN WDPRS has been effectively circumvented by the owners of this criminal domain. The domain has had 3 different sets of false WHOIS and simply transferred their domain each time a complaint was filed. The domain had been transferred to 4 different registrars and is currently operating selling narcotics. In short, the current system has failed in its intent and the criminals now know how to get around enforcement. The problem is in the contract and in the compliance procedures. This is related to the earlier studies I have released to the list. I will be presenting at the joint session of the Public Safety Working Group (PSWG) and the Verified TLD (vTLD) constituency on Tuesday 14 March from 18:30 to 19:30 in Hall B4.1. I invite all comments and will be talking about this in meetings. Apologies for any cross-posting. -Garth -- Garth Bruen gbruen@knujon.com 617-947-3805 http://www.knujon.com ICANN At-Large Advisory Council Author: WHOIS Running the Internet http://www.wiley.com/WileyCDA/WileyTitle/productCd-1118679555.html